PO Box 2, Omarama.
Ph 027 221-4739
e-mail: bill@chisholm.co.nz
2nd October 2012
To:
Canterbury Regional Council
Re: Proposed Canterbury Land & Water Regional Plan
This is a submission on behalf of Aquatic Weed Control Ltd, a company which retails
herbicides used for aquatic weed control, and provides consultancy advice on same. This
submission is primarily concerned with Rules 5.25, 5.26,5.27, 5.28 and 5.143 of the Plan.
It should be noted that the only hazardous chemicals which can legally be discharged to water
in accordance with the Hazardous Substances and New Organisms Act 1996 are the
following:
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

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Diquat
Aquathol K
Aquathol Super K
Garlon 360
Four other chemicals are currently under application to the Environmental Protection Agency
for discharge to water. However, these EPA applications are currently being processed, and
there are significant concerns about their use, so their approval is not guaranteed.
Glyphosate is not registered for use in water. Therefore, Rule 5.27 (as it is currently worded)
is not legal. The Environmental Protection Agency has previously expressed concerns about
the somewhat permissive Council rules relating to discharge of chemicals into water,
especially diquat. EPA have placed a requirement for a separate “permission”, under S 95 A
of the Hazardous Substances and New Organisms Act 1996, for the discharge of Aquathol K
and Aquathol Super K, as a direct consequence of these concerns.
Accordingly, the permitted activity rules expressed in Rule 5.25 need to be re-drafted to
exclude these hazardous substances (i.e. they should be restricted discretionary activities).
Rule 5.27 should delete reference to glyphosate, as it is not allowed to be discharged to water.
Rule 5.27 should include diquat, Aquathol, Aquathol Super K and Garlon; and require these
activities to be restricted discretionary, not permitted. This is because of EPA concerns, the
highly technical nature of these discharges, and the potential for significant adverse effects if
the discharges are not carried out properly.
It might be useful for Rule 5.28 to refer to biosecurity outcomes. Discharge of these
substances for aquatic weed control may be because of biosecurity incursions, which could
happen anywhere. The Plan should cater for this.
Rule 5.143 (6) and (7) should allow for destruction of indigenous aquatic plants in these
areas, if it relates to a biosecurity incursion or other emergency.
I wish to be heard in support of this submission.
If others make a similar submission I will consider presenting a joint case with them at
a hearing
Yours faithfully
Bill Chisholm – Owner/manager
AQUATIC WEED CONTROL LTD
Address for service of submitters:
C/- Aquatic Weed Control Ltd, PO Box 2, Omarama 9448.
E-mail: bill@chisholm.co.nz
Phone: (027) 2214739